Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees by exposing them to serious fire and explosion hazards. %% a) On or about March 3, 1991, the main block valve at the bottom of the F-7 was closed with prevented water from draining out of the CUU "A" during the start-up procedure. Consequently, hot oil was mixed with water, in the F-7 Slurry Settling Drum for the CUU "A", thereby causing a catastrophic failure of the slurry settling drum, releasing flammable and combustable liquids, gases, and vapors. %% NOTE: A feasible and useful method among others of correcting this hazard is to provide a strickly enforce the use of a detailed written start-up procedure with signed and dated logs for specific task(s). %% b) Employer did not comply with the applicable provisions of the API 510, ASME Boiler and Pressure Vessel Code, Section V, Vii, and IX and American Society for Nondestructive Testing, Code for Qualifications of Welders, Welding Inspectios, and Pressure Vessel Inspectors including, but not limited to, API 510, Section 5, Paragraph 5.2.1; ASME Boiler and Pressure Vessel Code, Section IX, Welding and Brazing Qualifications Section V, Paragraph 2.2 and American Society for Nondestructive Testing, Parts 5 and 6, thereby exposing employees to the hazard of inadequate welds on pressure vessels. %% NOTE: A feasible and useful method among others of correcting this hazard is to ensure that persons who are authorized to perform and interpret Non-Destructive Testing (NDT) are qualified to American Society of Non-Destructive Testing (ASNT) SNT-TC-14 or equivalent written requirements or written procedures in accordance with ASME Boiler and Pressure Vessel Code, Section V, 1989. %% c) On or about March 3, 1991, oil collected behind a re-enforcing pad for a nozzle on the E-1 tower, the oil then contracted the atmosphere and ignited. The E-1 Tower, the oil then contacted the atmosphere and ignited. The E-1 Tower was not shutdown nor was it properly evaluated to determine if it was safe to continue operation. %% NOTE: A feasible and useful method among others of correcting this hazard is to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each process and address at least the following: a) steps for each operating phase, b) operating limits, and c) safety and health considerations. Such procedures may require that the vessel be shut down until it has been properly repaired and re-inspected or that a ualified engineer determine if it is safe to continue operations.

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